Guo Wengui / Miles Guo — criminal case · JUDGMENT · ECF #81-5

# EXHIBIT B

*United States v. Yanping Wang*, Case No.: S1 23-CR-118 (AT)

### SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK

YANPING WANG a/k/a YVETTE WANG,

Plaintiff,

v.

XIANMIN XIONG a/k/a XI NUO a/k/a SINO,

Defendant.

Index No.: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Date Purchased: \_\_\_\_\_\_\_\_\_\_\_\_\_\_

Plaintiff designates New York County as the place of trial.

The Basis of the venue is Plaintiff's place of residence (New York County) pursuant to CPLR 503(a)

### **SUMMONS**

### **TO THE ABOVE-NAMED DEFENDANT:**

**YOU ARE HEREBY SUMMONED** to answer the Verified Complaint in this action and to serve a copy of your answer on the Plaintiff's attorneys indicated below, within 20 days after the service of this summons, exclusive of the day of service (or within 30 days after the service is complete if this summons is not personally delivered to you within the State of New York); and in case of your failure to appear or answer, judgment will be taken against you by default for the relief demanded herein.

Dated: New York, New York August 8, 2019

TO: Xianmin Xiong 136-84 Roosevelt Avenue, Apt. A83 Flushing, New York 11354

### **CATAFAGO FINI LLP**

/s/ Tom M. Fini

Tom M. Fini, Esq. Jacques Catafago, Esq. The Empire State Building 350 Fifth Avenue, Suite 7710 New York, NY 10118 212-239-9669 tom@catafagofini.com *Counsel for Plaintiff*

### SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK

YANPING WANG a/k/a YVETTE WANG,

Plaintiff,

v.

Index No.: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

XIANMIN XIONG a/k/a XI NUO a/k/a SINO,

Defendant.

**VERIFIED COMPLAINT**

Plaintiff Yanping Wang a/k/a Yvette Wang (hereinafter "Plaintiff"), for her complaint against defendant Xianmin Xiong a/k/a Xi Nuo a/k/a Sino (hereinafter "Defendant"), by undersigned her counsel, states the following:

### **INTRODUCTION**

1. This action is brought to redress Defendant's ongoing campaign of threats, defamation and harassment directed to the Plaintiff, which has now culminated in Defendant approaching the Plaintiff and threatening to kill her. Indeed, after Defendant's recent death threat to the Plaintiff, he continues to stalk Plaintiff directly outside her place of work.

2. Plaintiff accordingly seeks, among other things, compensatory and punitive damages, and an order enjoining Defendant from continuing his malicious and relentless campaign of defamation, harassment, and intimidation, and from further tarnishing Plaintiff's reputation.

### **PARTIES AND JURISDICTION**

3. Plaintiff is a female individual, who was at all times relevant hereto an adult resident of New York County, in the State of New York.

4. Defendant is a male individual, who, upon information and belief, was at all times relevant hereto an adult resident of the State of New York.

5. Jurisdiction is proper as both parties are residents of New York State.

6. Venue is proper as Plaintiff resides in New York County (CPLR 503(a)), and

Defendant committed many of the tortious acts detailed herein in New York County.

### **BACKGROUND**

### **Defendant's Ongoing Defamation and Harassment of the Plaintiff**

### **Background of the Harassment Campaign**

7. Defendant's campaign to terrorize Plaintiff began with his repeated and malicious posting of false and defamatory material on online social media platforms regarding the Plaintiff. As detailed below, these defamatory posts include the blatantly false allegations that: Plaintiff, who is a married woman, is involved in an extra-marital sexual relationship with another man; that Plaintiff has supposedly been raped by a work colleague; that Plaintiff has destroyed evidence relevant to a legal proceeding; and that Plaintiff has engaged in wrongful interrogation and detention of an alleged witness in a legal proceeding. Defendant made all of these false allegations knowing they were false, and with the malicious intent to destroy Plaintiff's reputation and career, and instill terror in her on a daily basis.

8. These defamatory statements are particularly egregious because Plaintiff is not a public figure, and is instead an innocent woman – a wife and mother – who is a private individual working for a private company.

9. Defendant's campaign against Plaintiff is persistent and continuing. For example, on August 26, 2017, Defendant posted on his Twitter account to his approximately 31,500 followers that Plaintiff, referred to as "Sister Yanping," had an intimate relationship with a man named "Robert." Specifically, Defendant tweeted the following defamatory statement: "Robert has an intimate relationship with Sister Yanping. He doesn't have a decent stance but only cares about the money." A full and correct copy of the tweet and a certified translation is attached hereto as Exhibit A.

10. The above defamatory tweet conveys a false statement of fact to the public regarding Plaintiff, namely, that Plaintiff – a married woman – is having an extramarital intimate relationship with a man named Robert.

11. Subsequently, on September 5, 2017, Defendant posted another outrageous and defamatory comment regarding Plaintiff, this time purporting to quote a fake interview that Defendant falsely claims that Plaintiff gave about her relationship with her male work colleague, Guo Wengui. Specifically, Defendant tweeted that:

> Wang Yanping denied today that the recording of her having sex with Guo Wengui published on Twitter was true. She even totally denied the recorded conversation between her and Ma Rui was true. She did not comment at all on the alleged rape Guo Wengui involved.

A full and correct copy of the tweet and a certified translation is attached hereto as Exhibit B.

12. The above statements by Defendant again convey false and defamatory statements of fact to the public regarding Plaintiff. Specifically, Defendant falsely alleges that Plaintiff had sex with a man other than her husband, and that Plaintiff is complicit in the rape of another woman.

13. The next day, on September 6, 2017, Defendant again posted a defamatory tweet about Plaintiff. In this post, Defendant presented a fake dialogue between Plaintiff (referred to as "Yan") and another woman (referred to as "Ma"). This phony dialogue conveys to the public that the Plaintiff helped intimidate Ma Rui and participated in the intimidation of a witness to a crime. Specifically, Defendant tweeted the following:

> Yan: I love sister Ma very much, she is a very innocent kid. Ma: You helped bad people to victimize the weak and detained me in the apartment. Yan: She is introverted and may suffer depression. Ma: You grabbed my cellphone and forced me not to call the police.

Yan: All the so-called conversation recordings between Wang Yanping and Ma Rui on the internet are fake.

Ma: You may think that you can deceive some people, and you can deceive them for some period of time, but you will never be able to deceive everyone forever.

A full and correct copy of the tweet and a certified translation of its text is attached hereto as

Exhibit A.

14. The above tweet makes a false and defamatory statement of fact to the public regarding Plaintiff. Specifically, it accuses Plaintiff of illegally detaining and threatening another woman, and conveys to the public that Plaintiff is lying about her involvement in these illegal actions.

15. Less than a month later, on October 12, 2017, Defendant again posted another defamatory tweet regarding the Plaintiff. Specifically, Defendant tweeted:

> Wang Yanping: You have to think clearly. The case of Ma Rui is going to be a criminal case. You definitely will become one of the defendants, because you are suspected of assisting Guo Wengui in destroying the forensic evidence. You should first sue Guo Wengui for sexual assault at this critical moment, after all it is the truth. You have been terribly deceived by Guo Wengui-- you cannot go back home and you have been separated from your child and husband out of your choice. Once you are sued in court, it will be very hard to turn things around. Be smart and sue Guo Wengui immediately to turn the table around and take the situation under your control.

A full and correct copy of the tweet and a certified translation is attached hereto as Exhibit A.

16. The above defamatory tweet conveys a false statement of fact to the public regarding Plaintiff, that is, that Plaintiff has assisted in destroying evidence relevant to a crime, that Plaintiff was sexually assaulted, and that Plaintiff allows herself to be sexually assaulted.

17. The above defamatory statements – which are false and have no basis in fact – were made by Defendant with malice and knowledge of their falsity could only be said with the intent to cause the direct and proximate harm of ruining Plaintiff's reputation, her business relationships, and her relationship with her husband.

### **The Defamatory Statements for Which Plaintiff Asserts Defamation Claims**

18. Defendant's campaign to terrorize the Plaintiff has not only continued, but has but has increased in its ferocity and plain intent to completely destroy Plaintiff's family life and career. As part of this campaign to destroy the Plaintiff's life, the Defendant embarked on the below series of internet postings, all aimed to destroy the Plaintiff's reputation and isolate her from her family.

19. On January 18, 2019, Defendant posted a tweet falsely accusing Plaintiff of plagiarizing the signature of her work colleague Guo. Specifically, Defendant's tweet stated that:

> It has been learned that the counsel Daniel Watt who is retained by Guo Wengui for a lawsuit against Xia Yeliang and Li Hongkuan has already applied for withdrawal. What is surprising is that in **Guo Wengui's confirmation letter that Daniel submitted to the court is actually signed in Yanping's handwriting**. [emphasis added]

A full and correct copy of the tweet and a certified translation is attached hereto as Exhibit C.

20. The above defamatory tweet by the Defendant conveys a false and defamatory statement of fact to the public regarding Plaintiff. Specifically, the tweet falsely conveys that Plaintiff has illegally fabricated evidence relevant to a legal proceeding.

21. On April 26, 2019, a YouTube video was uploaded in which the Defendant

discussed Ms. Wang's testimony in a trial. Specifically, the Defendant states that:

So I will tell you guys about the situation of the trial this morning. There were three witnesses being examined in the morning and the first one who testified was Wang Yanping….The counsel then asked her if she knew about the purchase of this building by XXX, the off-shore company. She replied she didn't know. Yet, the counsel held a pile of papers and said, "You signed all these papers, but you knew nothing about these?" **She then stammered and said she was super nervous, she had already forgotten these matters and please pardon her. So, it was obvious that she had lied on these matters.** [emphasis added]

A true and correct copy of the relevant excerpts of the transcript of the YouTube video and a certified translation are attached hereto as Exhibit B.

22. Defendant's description of Plaintiff's testimony as quoted above is false and clearly

conveys a defamatory statement of purported fact to the public regarding Plaintiff, specifically,

that Plaintiff has illegally provided false testimony under oath.

23. Two days later, on April 28, 2019, Defendant posted yet another defamatory tweet

about the Plaintiff. In this new tweet, Defendant falsely alleges that Plaintiff has knowledge of a

sexual assault which she is not reporting. Specifically, Defendant tweeted that:

**If Wang Yanping wants to save her own ass, the only way is to file a report in the police station, accusing someone for sexual assault**. The evidence is very easy and simple, there are a lot of audio clips online. If she still cares about losing her face in public at this point, she is too stupid. [emphasis added]

A full and correct copy of the tweet and a certified translation is attached hereto as Exhibit C.

24. Two weeks later, on May 12, 2019, Defendant again falsely tweeted about

Plaintiff's alleged failure to report a sexual assault, specifically tweeting:

I told Wang Yanping that you have no future if you follow Guo Wengui. Guo never has any loyalty to his friends. He uses people when they have value to him and he throws them away like a piece of cleaning shred if they have lost their value to him. **I hope that she can report to the NYPD accusing Guo Wengui raping and assaulting her.** This action will turn her situation from losing to winning [emphasis added]

A full and correct copy of the tweet and a certified translation is attached hereto as Exhibit C.

25. On that same day, May 12, 2019, Defendant also tweeted that:

**There was an occasion where Guo Wengui assaulted Wang Yanping after he got drunk. Not only did he rape Wang, he also stepped on her belly violently**. There was a recording of this audio clip online. It seems that Wa Li was there at that time too. [emphasis added]

A full and correct copy of the tweet and translation is attached hereto as Exhibit C.

26. The above-quoted three tweets clearly convey false and defamatory statements of fact to the public regarding the Plaintiff. Specifically, the tweets falsely convey that Plaintiff is a rape victim, and that Plaintiff is having sex with another man, despite being married. The tweets also falsely convey that Plaintiff is obstructing justice by not reporting crimes of which she is supposedly aware.

27. On June 7, 2019, Defendant posted yet another tweet, in which he falsely accused

Plaintiff of "interrogating" Ma Rui. Specifically, Defendant tweeted that:

**Since the exposure of the audio clip about Guo Wengui and his secretary Wang Yanping interrogating Ma Rui together**, Ms. Wang accepted the interview from Der Spiegel, leaving recorded proof of her voice. **After verification from the Australian judicial authorities, the audio clip of Wang Yanping having an interview with Der Spiegel is the same as the audio clip of her interrogating Ma Rui**. This evidence has already been submitted to the court. [emphasis added]

A full and correct copy of the tweet and translation is attached hereto as Exhibit C.

28. The above tweet clearly conveys a false and defamatory statement of fact to the public regarding Plaintiff, that is, that Plaintiff has been involved in the improper interrogation of a witness to a legal proceeding.

29. On July 11, 2019, Defendant posted another tweet falsely stating that Plaintiff (referred to as "Wangyanping") and Guo Wengui interrogated Ma Rui and coerced her into destroying evidence. Specifically, Defendant alleges the following:

> I have listened to the recording of Guo Wengui and Wangyanping's interrogation on Ma Rui 5 times. **There are 9 occasions where Ma Rui was coerced to hand over the evidences of being raped**, for example, the underwear contaminated by bodily fluid, the blood-stained bed sheet, the name of the pharmacy for getting birth-control pills, the number of times of being raped, the locations of the offenses and whether or not the boat staff and security guards were present etc. [emphasis added]

A full and correct copy of the tweet and translation is attached hereto as Exhibit C.

30. The above tweet clearly makes false and defamatory statements of fact to the public regarding Plaintiff, that is, that Plaintiff improperly interrogated and illegally coerced a witness to a legal proceeding into destroying evidence.

31. On July 13, 2019, Defendant again posted a defamatory tweet about the Plaintiff, falsely asserting that there is an alleged tape recording of Plaintiff and Guo Wengui interrogating Ma Rui. Specifically, Defendant tweeted that: "There are 3 main pieces of evidence that support the charge against Guo Wengui as a rapist: 3. **The one-hour-forty-minute audio clip of Guo Wengui and Wang Yanping interrogating Ma Rui**[.]" [emphasis added] A full and correct copy of the tweet and translation is attached hereto as Exhibit C.

32. The above defamatory tweet conveys false and defamatory statements of fact to the public regarding Plaintiff, specifically that Plaintiff participated in a nearly two-hour improper interrogation of Ma Rui, a witness to a legal proceeding.

33. On July 13, 2019, Defendant posted a tweet containing a link to a YouTube video. Defendant describes the video as: "**Pangu Boss Guo Wengui having sex with female secretary Wang Yanping in office[**.]" [emphasis added]. A full and correct copy of the tweet and translation is attached hereto as Exhibit C.

34. The above defamatory tweet conveys a false and defamatory statement of fact to the public regarding Plaintiff, specifically that Plaintiff, a married woman, has had sex at the office with a male colleague.

35. Later that day, Defendant posted another defamatory tweet referencing the same video. Specifically, Defendant tweeted, in relevant part:

## **New evidences that support Guo Wengui as a suspect of rape are:** \*\*\*

### 4. **The audio clip of Guo Wengui raping and assaulting Wang Yanping**

[emphasis added]

A full and correct copy of the tweet and translation is attached hereto as Exhibit C.

36. The above defamatory tweets convey a false statement of fact to the public regarding Plaintiff, specifically that Plaintiff has been raped and assaulted, and that Plaintiff, a married woman, has had sex with another man.

### **Defendant's Harassment Campaign Culminates with Defendant Making an In-Person Death Threat Against Plaintiff**

37. Defendant's campaign to terrorize the Plaintiff, and completely destroy her family life and business reputation, has now shockingly progressed to the point where Defendant has made an in-person death threat against the Plaintiff.

38. Specifically, on April 26, 2019, Defendant approached the Plaintiff outside of courtroom 232 in the New York County Supreme Court, located at 60 Centre Street, and ominously sat next to her, despite her request that he leave her alone. The Defendant's approaching the Plaintiff after terrorizing her for many months in defamatory postings obviously placed her in fear of bodily harm, and she repeatedly asked Defendant to leave her alone, which he refused.

39. Ignoring the Plaintiff's pleas to be left alone, the Defendant then did the unthinkable: he issued her a death threat, while jutting and raising his fists and arms threateningly toward her face and body. Specifically, Defendant stated to the Plaintiff, while raising his fists toward her:

### **"You will be killed in a car accident."**

### **"You will never see your child or your husband again."**

### **"You are throwing your life away."**

40. The Defendant's death threats issued to Plaintiff as he sat next to her placed Plaintiff in fear of her life. Plaintiff again pleaded for the Defendant to leave her alone. Yet, faced with the Plaintiff terrorized and in tears, Defendant persisted in his course of terror against Plaintiff, an innocent woman. The Defendant hurled his head and arms toward the Plaintiff and continued with his verbal abuse and assault.

41. To further make clear to Plaintiff that her life was in danger, the Defendant referenced the untimely death of a Chinese dissident residing in France of similar approximate age as Plaintiff. Plaintiff lived in France for a number of years.

42. Defendant made his death threat to the Plaintiff intentionally, with malice, and with the actual intent to cause the Plaintiff to fear serious bodily harm or death. Defendant's statements were objectively meant to invoke fear in Plaintiff and convey that the Plaintiff and her family would suffer serious bodily injury and death.

### **Defendant Escalates His Death Threat by Appearing at Plaintiff's Doorstep, And Engaging in Violence to Terrorize Her**

43. The Defendant's terrorizing behavior did not stop with the death threat issued in the courthouse. Following the April 26, 2019 threat on her life, the Defendant has now escalated the death threat by coming directly to her doorstep and engaging in acts of violence, all making clear that Defendant is prepared to carry out the threat on her life. As discussed below, Defendant has repeatedly come to Plaintiff's place of work, despite the fact that he does not live or work on that block, and has acted violently even when security was called.

44. There is no reasonable basis for Defendant to be near Plaintiff's place of work as Defendant does not work or live on the block where Plaintiff's office is located. The only reason for this behavior is to instill imminent fear of bodily harm in Plaintiff.

45. First, on July 25, 2019, having recently made the in-person death threat against the Plaintiff, Defendant suddenly appeared directly outside the building where Plaintiff works (162 E. 64th Street, New York County, New York). Defendant menacingly lurked outside the building for at least thirty minutes.

46. The following day, on Friday, July 26, 2019, the Defendant *again* menacingly appeared outside of Plaintiff's place of work (162 E. 64th Street), and remained there for at least thirty minutes. Subsequently, on Saturday, July 27, 2019, Defendant again appeared outside Plaintiff's place of work (162 E. 64th Street), and remained ominously outside the front door of the building for at least thirty minutes.

47. Thereafter, on Monday July 29, 2019, Defendant again menacing appeared directly outside the building where Plaintiff works. Because the Defendant had appeared outside of Plaintiff's work so many times, this time Plaintiff had a member of a security team go out to ask Defendant what his purpose was. Shockingly, rather than leaving, the Defendant confronted a member of the security team, lunging his body and arms toward the security team member in a violent manner.

48. Defendant's defiance and acts of violence toward a security officer has only heightened the very real fear of serious bodily injury and death that the Plaintiff has as a result of the Defendant's ongoing acts of harassment, intimidation, violence and death threats.

49. Indeed, despite his interaction with the security guard the previous day, the Defendant again menacingly appeared the very next day (July 30, 2019) directly outside of the building where Plaintiff works and attempted to **gain access to the building**. This was clearly in an attempt to harm and harass Plaintiff and further showing that the Defendant has malicious intent and that he is completely undeterred by any security team.

50. Plaintiff, fearing for her safety and well-being, filed a police report with the NYPD, and it is Plaintiff's understanding that an investigation into the Defendant's criminal conduct ensued and is ongoing.

### **Defendant's Campaign of Ongoing Harassment Has Also Caused Serious Emotional and Ecomonic Damages, and Destruction of Her Marriage**

51. Defendant's malicious defamation campaign has caused Plaintiff serious damage to her reputation. Defendant's malicious defamation campaign has also caused the destruction of Plaintiff's marriage and prevented her from seeing her young son, as it has included, among other things, the false allegation of an ongoing extra-marital sexual relationship. As a result of the destruction of her reputation and marriage, Plaintiff has suffered extreme emotional distress.

52. Defendant's malicious defamation campaign has also caused Plaintiff substantial damages to her business contracts and relationships. Plaintiff is a consultant in the financial industry, specializing in providing advice as to the local customs, regulations, and policies that exist in mainland China. Her reputation as an honest and trustworthy business woman is essential to her trade. Thus, Defendant's defamatory statements that Plaintiff is engaged in extramarital affairs, the destruction of evidence, and the interrogation and intimidation of witnesses to criminal conduct clearly injure her in her line of business.

53. For example, because of Plaintiff's deep experience with and knowledge of Chinese business practices, Plaintiff had a lucrative consulting contract with ACA Investment Management Limited ("ACA"), under which Plaintiff advised a Hong Kong business on local customs, regulations, and policies that exist in mainland China.

54. Under the contract with ACA, Plaintiff was to receive \$1.5 million a year.

55. Defendant was aware of Plaintiff's contract with ACA, and her prospective business relationship with ACA. Defendant maliciously intended to destroy Plaintiff's business relationships, including with ACA, by publicly defaming her as set forth in detail above.

56. Defendant succeeded in destroying Plaintiff's business relationship with ACA. After Defendant began his internet campaign to destroy Plaintiff's reputation, ACA contacted Plaintiff in or about August 2017 and informed her that the Defendant's allegations regarding Plaintiff were not consistent with the image it needed to portray to its client base and business counterparts, and that as a result of the negative publicity, ACA would terminate their relationship with the Plaintiff.

57. Thus, Defendant's malicious defamation of the Plaintiff not only terrorized her, destroyed her reputation and destroyed her relationship with her husband and family, but has also directly and proximately interfered with her contract and prospective business relationship with ACA.

58. Indeed, as a result of the termination of her contract with ACA, Plaintiff lost millions of dollars in damages from the loss of this business relationship alone.

### **FIRST CLAIM FOR RELIEF** (Assault)

59. The above paragraphs are repeated and incorporated by reference as if fully set forth herein.

60. Defendant's physical confrontation of the Plaintiff on April 26, 2019, including his raising of his fists toward the Plaintiff and issuing her a death threat (as set forth above in detail), was intended to place Plaintiff in apprehension of serious harmful or offensive contact and in great fear of imminent serious bodily injury and death.

serious bodily injury and death, and has suffered severe emotional distress.

62. As a result of the Defendant's assault, Plaintiff has suffered, and will continue to suffer, damages to be proven at trial.

63. In addition to monetary damages, Plaintiff is also entitled to preliminary and permanent injunctive relief, including enjoining the Defendant from coming near the Plaintiff or her place of residence or business, or issuing any further threats to Plaintiff or her family.

64. Plaintiff is entitled to an award of compensatory damages in an amount to be determined at trial. In addition, Defendant's actions were deliberate, willful, intentional, wanton, malicious, and oppressive and in conscious disregard for the rights of Plaintiff, and should be punished with an award of punitive damages in an amount to be determined at trial.

### **SECOND CLAIM FOR RELIEF** (Defamation)

65. The above paragraphs are repeated and incorporated by reference as if fully set forth herein.

66. The defamatory statements that are set out with particularly in paragraphs 18 to 36 above and that Defendant published on his social media profiles about Plaintiff have no basis in fact, are false and defamatory, and are not the subject of any privilege.

67. Defendant had actual knowledge that the information he published was false, and he acted with malice, including the intent to harass the Plaintiff and destroy her reputation and business. In the alternative, in knowingly publishing highly derogatory information about a private figure (the Plaintiff), Defendant in the least acted in a grossly irresponsible manner and without due consideration for the standards of information gathering.

68. Defendant's published false comments regarding the Plaintiff were made with the intent to harm Plaintiff and with actual malice.

69. Defendant's defamation has directly and proximately caused Plaintiff's special damages, including but not limited to damage to her reputation, her business relationships, her relationship with her husband and child, and severe emotional distress.

70. In addition to monetary damages, Plaintiff is also entitled to preliminary and permanent injunctive relief, including enjoining the Defendant's defamation and interference with business relations. Because Defendant has placed Plaintiff's personal character and reputation publicly at issue, Plaintiff is entitled to a declaratory judgment that Defendant's statements are false.

71. Plaintiff is entitled to an award of compensatory and punitive damages in an amount to be determined at trial.

### **THIRD CLAIM FOR RELIEF** (Defamation Per Se)

72. The above paragraphs are repeated and incorporated by reference as if fully set forth herein.

73. The defamatory statements that are discussed in paragraphs 18 to 36 and that Defendant published on his social media profiles about Plaintiff are false and defamatory, and not the subject of any privilege.

74. Defendant had actual knowledge that the information he published was false, and he acted with malice, including the intent to harass the Plaintiff and destroy her reputation. In the alternative, in knowingly publishing highly derogatory information about a private figure (the Plaintiff), Defendant in the least acted in a grossly irresponsible manner and without due consideration for the standards of information gathering.

75. Defendant's false statements concerning the Plaintiff include accusations that Plaintiff has committed serious crimes, and are of the type that tend to injure Plaintiff in her trade, business, and profession and impute salacious and immoral conduct to Plaintiff. Defendant's false statements about Plaintiff made to public include the following: that Plaintiff, who is a married woman, is involved in an extra-marital sexual relationship with another man; that Plaintiff has supposedly been raped by a work colleague; that Plaintiff has destroyed evidence relevant to a legal proceeding; and that Plaintiff has engaged in wrongful interrogation and detention of an alleged witness in a legal proceeding.

76. The published false comments were made with the intent to harm Plaintiff and with actual malice.

77. Defendant's defamation has directly and proximately caused Plaintiff's damage, including but not limited to damage to her reputation, her business relationships, her relationship with her husband and child, and severe emotional distress.

78. The injurious character of Defendant's false statements is a self-evident fact of common knowledge which not be pleaded or proved.

79. As such, Defendant's false statements are actionable without proof of special damages.

80. In addition to monetary damages, Plaintiff is also entitled to preliminary and permanent injunctive relief, including enjoining the Defendant's defamation and interference with business relations.

81. Because Defendant has placed Plaintiff's personal character and reputation publicly at issue Plaintiff is entitled to a declaratory judgment that Defendant's statements are false.

## **FOURTH CLAIM FOR RELIEF**

(Tortious Interference with Contract)

82. The above paragraphs are repeated and incorporated by reference as if fully set forth herein.

83. Plaintiff had a valid contract with ACA for consulting services.

84. Defendant was aware of Plaintiff's contract with ACA.

85. Defendant intentionally interfered with Plaintiff's contract with ACA by intentionally inducing ACA to breach the contract.

86. Defendant acted solely out of malice or wrongful means.

87. As a direct and proximate result of Defendants malicious and wrongful actions,

ACA breached its contract with Plaintiff. But for Defendant's wrongful conduct, ACA would not have breached its contract with Plaintiff.

88. As a direct and proximate result of the Defendant's malicious and wrongful actions, Plaintiff has suffered damages. To compensate for these damages, Plaintiff is entitled to an award of compensatory and punitive damages in an amount to be determined at trial.

## **FIFTH CLAIM FOR RELIEF**

(Tortious Interference with Prospective Business Relations)

89. The above paragraphs are repeated and incorporated by reference as if fully set forth herein.

90. Plaintiff had a business relationship with ACA.

91. Defendant knew of Plaintiff's business relationship with ACA and intentionally interfered with it.

92. Defendant acted solely out of malice or wrongful means.

93. Defendant's interference directly and proximately caused injury to Plaintiff's relationship with ACA, as evidenced by ACA terminating its business relationship with Plaintiff. As a direct and proximate result of Defendant's malicious and wrongful actions, ACA ended its ongoing business dealings with the Plaintiff. But for Defendant's wrongful conduct, ACA would have continued its business relationship with the Plaintiff.

94. As a direct and proximate result of the Defendant's misconduct, Plaintiff is entitled to an award of compensatory and punitive damages in an amount to be determined at trial.

### **PRAYER FOR RELIEF**

**WHEREFORE**, Plaintiff prays for judgment against Defendant as follows:

- (a) An award of compensatory and punitive damages in an amount to be determined at trial; - (b) Preliminary and permanent injunctive relief enjoining Defendant and his respective agents, servants, employees, officers, and assigns, and all other persons acting in active concert or participation with him, from further publication of any false, malicious, defamatory or materially misleading comments regarding Plaintiff, or issuing any death threats to Plaintiff; - (c) Preliminary and permanent injunctive relief enjoining Defendant and his respective agents, servants, employees, officers, and assigns, and all other persons acting in active concert or participation with him, from coming near the Plaintiff or her place of residence or business; - (d) a declaratory judgment that Defendant's comments regarding Plaintiff are false; - (e) an award of attorneys' fees, costs, and expenses; and - (f) such other and further relief as the Court deems just and proper.

NYSCEF DOC. NO. 1

NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/08/2019

Dated: New York, New York August 8, 2019

### **CATAFAGO FINI LLP**

/s/ Tom M. Fini Tom M. Fini, Esq. Jacques Catafago, Esq. The Empire State Building 350 Fifth Avenue, Suite 7710 New York, NY 10118 212-239-9669 tom@catafagofini.com *Counsel for Plaintiff*


### VERIFICATION

STATE OF NEW YORK ) ) ss: COUNTY OF NEW YORK )

I, Yanping Wang, am the Plaintiff in the above entitled action. I have read the foregoing Complaint and know the contents thereof. The contents are true to my own knowledge except as to matters therein stated to be alleged upon information and belief, and that as to those matters, I believe them to be true.

YANPING WANG

Subscribed and Sworn to before me on this EA date of August 2019

Ullioistbello J. NOTARY PUBLIC

KARIN MAISTRELLO NOTARY PUBLIC STATE OF NEW YORK Registradon No. orMA6376654 Qgdined in NY County Commision expiresJune, 182012

## EXHIBIT A

AFFIDAVIT

STATE OF NEW YORK )

) ss

COUNTY OF QUEENS )

STATE OF NEW YORK ) ) ss: COUNTY OF QUEENS )

I, Shenyi Glass, am ^a linguist hired by TransPerfect, ^a translation services that operates under both ISO 9001:2008 and EN 15038:2006 certification. ^I have been speaking Mandarin dialect of Chinese for ⁵⁰

years. ^I am ^a recipient of Certifications for New York State Court Interpreter and National Healthcare

The following document is, to the best of my knowledge and belief ^a true and accurate translation from Chinese into English:

Interpreter. I have studied Mandarin translation for 5 years.

The Attached Social Media Posts TransPerfect Translations, Inc., ^a translation organization with over 90 offices on six continents, is ^a

translating into the above language pair, its work being accepted by business organizations, governmental

Tuesday, August 07, 2019

Shengi Rivers

henyi Glass,

Mandarin Interpreter & Translator

TransPerfect Translations, Inc. affirms that the provided translation was produced in according to our ISO 9001:2015 and ISO 17100:2015 certified quality management system, and also that the agents responsible

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Sworn to before me this Wednesday, August 07, 2019

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Stamp, Notary Public

NOTARY PUBLIC-STATE OF NEW YORK No. 01 SH6352366 Qualified in Omos County My Commission Exµiies 12-2 1-26z6


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was from \$US75,000 to \$US100,000 for per mailbox that is

http

| | <p><b>西诺</b></p> <p>@sinofreedom</p> | <span>Follow</span> | |--|--------------------------------------|---------------------| |--|--------------------------------------|---------------------|

王雁平：你要想明白了，马蕊一案将要刑诉，

你必然要成为被告之一，因为你有协助郭文贵

毁灭犯罪证据的嫌疑，在这个关键时刻你必须

抢先控告郭文贵性侵，这本来就是事实，你已

经被郭文贵骗的很惨，有家不能回，有孩子老

公活活拆散。你被告上法庭就很难翻身了，

聪明一点立刻把郭告了，变被动为主动。

Translate Tweet

7:55 PM - 12 Oct 2017

**199** Retweets **66** Likes

**FILED: NEW YORK COUNTY CLERK 08/08/2019 06:22 PM** INDEX NO. 157786/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/08/2019

Follow

Translate Tweet 7:55 PM - ¹² Oct 2017

Wangianping: You have to t1 ^k clearly. The case of Ma Rui is going to be ^a criminal case.

You definitely will become one of the defend5mts, because you are suspected of assisting Guo Wengui in destroying the forensic evidence. You should first sue Guo Wengui for sexual assault at this critical moment, after all it is the truth. You have been terribly deceived by Guo Wengui- you cannot go back home and you have been separated from your child and husband out of your

choice. Once you are sued in court, it will be very hard to turn things around. Be smart and sue

Guo Wengui immediately to turn the table around and take the situation under your control.

199 Retweets 66 Likes


@ Translate Tweet

Robert has an intimate relationship with Sister Yanping (Wang Yanping). He doesn't have ^a

o

5:34 AM - ²⁶ Aug ²⁰¹⁷

decent stance but only cares about the money.


**FILED: NEW YORK COUNTY CLERK 08/08/2019 06:22 PM** INDEX NO. 157786/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/08/2019

MP , -B : MhttM , tBREME Nit 9. 5 : tatBP9F61 , M884tM5 . -B : B fBR taten , 52ieR¥t8 . 5 : M1ftF\$9

Follow


Translate Tweet

9:18 AM - 6 Sep 2017

9:18 AM -

internet are fake.

Yan: I love sister Ma very much, she is a very innocent kid.

Ma: You helped bad people to victimize the weak and detained me in the apartment.

Yan: She is introverted and may suffer depression.

Yanping's war against Ma (Rui).

Ma: You grabbed my cellphone and forced me not to call the police.

⁶ Sep 2017

Yan: All the so-called conversation recordings between Wang Yanping and Ma Rui on the internet are fake.

@remonwangxt

Ma: You helped bad people to victimize the weak and detained me in the apartment.

Yan: All the so-called conversation recordings between Wang Yañping and Ma Rui on the

Ma: You may think that you can deceive some people, and you can deceive them for some

@ Translate Tweet

Ma: You grabbed my cellphone and forced me not to call the police.

period of time, but you will never be able to deceive everyone forever.

Yan: ^I love sister Ma very much, she is ^a very innocent kid.

## EXHIBIT B

AFFIDAVIT

STATE OF NEW YORK ) ) ss COUNTY OF QUEENS )

STATE OF NEW YORK ) ) ss: COUNTY OF QUEENS )

I, Shenyi Glass, am ^a linguist hired by TransPerfect, ^a translation services that operates under both ISO 9001:2008 and EN 15038:2006 certification. ^I have been speaking Mandarin dialect of Chinese for ⁵⁰

years. ^I am ^a recipient of Certifications for New York State Court Interpreter and National Healthcare

The following document is, to the best of my knowledge and belief ^a true and accurate translation from Chinese into English:

Interpreter. I have studied Mandarin translation for 5 years.

The Attached Social Media Posts TransPerfect Translations, Inc., ^a translation organization with over 90 offices on six continents, is ^a

translating into the above language pair, its work being accepted by business organizations, governmental

authorities and courts throughout the United States and internationally.

henyi Glass,

Mandarin Interpreter & Translator

TransPerfect Translations, Inc. affirms that the provided translation was produced in according to our ISO 9001:2015 and ISO 17100:2015 certified quality management system, and also that the agents responsible

leader in professional translations. TransPerfect Translations, Inc. has over twenty years experience

for said translation(s) are qualified to translate and review documents for the above language pair, and are not ^a relation to any of the parties named in the source document(s).

Sworn to before me this Wednesday, August 07, 2019

Signature, Notary Public

Stamp, Notary Public

Stamp, Notary Public

NOTARY PUBLIC-STATE OF NEW YORK No. 01 SH6352366 Qualified in Omos County My Commission Exµiies 12-2 1-26z6

### 1. A conversation between Xi Nuo and Xia Yeliang

Xi Nuo: Yu Yong told me in person stating the most miserable person is Guo Mei.

夏业良：郭美住院的时候于泳陪着她呢是吧。另外还有他的儿子郭强好像也被他搞的……

Xia Yeliang: While Guo Mei (Miles Kwok's daughter) was admitted in the hospital, she was accompanied By Yu Yong, wasn't she? Also, it seems like his son Mileson Kwok was also messed up by him...

西诺: 郭强的, 就变成成灰了呀。郭强的女朋友是一个很漂亮的模特, 郭文贵趁着郭强出差的时候对她进行性侵了。

Xi Nuo: Mileson Kwok has become such a pitiable weak man. Mileson Kwok's girlfriend is a very beautiful model. Guo Wengui sexually assaulted her when Mileson Kwok went on a business trip.

Xia Yeliang: People said he committed incest...

Xi Nuo: The one who was involved in the incest is Wang Yanping.

Xia Yeliang: Wang Yanping is his (Guo Wengui's) nephew's wife.

西诺: 侄媳妇。所以就是这么说的。这个人下三滥,兔子也不吃窝边草啊。

Xi Nuo: Nephew's wife. That's why he was called a rotten piece of shit. Even the rabbit won't taste the grass in or around its cage.

夏业良：而且他经常骂郭强，他录音里……

Xia Yeliang: Also, he often scolded Mileson Kwok, in the recordings, he...

西诺：骂他是无能。郭强也是厌恶这个爹。为什么呢？你想想，哪个做爹的能把女儿儿子推到犯罪的第一线。你看看香港的那个案子里面，头一个起诉的不是郭文贵，是他女儿，还有他儿子。

Xi Nuo: Scolded him for incompetence. Mileson Kwok also despised this dad. Why? Just think, what kind of dad could push his own daughter and son to the frontline of the crimes? Check out the cases in Hong Kong--the first person to be sued is never Guo Wengui, but always his daughter and his son.

Xia Yeliang: That's how his children got ruined. Even the fierce tiger won't bite on its own cubs (Chinese idiom: everyone loves their own children).

**FILED: NEW YORK COUNTY CLERK 08/08/2019 06:22 PM** INDEX NO. 157786/2019 NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/08/2019

1513: RiflEAWBP, 5ARTR)JitRIE 805tW, TM19th\$950 R)é R2MBff3WRMitaRBOAEARM\$1%

Xi Nuo: We all have children. We encourage them to do proper things, but not illegal things. And I think people in An Hui-the hometown of Hushi (Province in Eastern China) all value the education very much.

R1R: \$E9744244&A? ftBOAM, EW atWEf)Rit, tett Xia Yeliang: How many members in Guo's family have been ruined by him? His eighth brother, when police made the arrest at that time...

1513: \$E1% EtPTitftA\$tW, f&t1\$f15†W800WP, 442% , RWMt1\$ftWP, ERTR\$27JR\$0

Xi Nuo: What Guo Wengui did at that time is that he grabbed the police officer's neck. When his younger brother saw that his big brother could grab the officer's neck, he brandished a kitchen knife and hacked!

Xia Yeliang: So he was killed by the police with a single shot.

### 2. http (2:37-3:35) Rfff\$2|jÈ GBSMedia

WM14FE\$895%

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1821199, itRR Super nervous, RARET, RB842t\$7R\*15 tL 19951% ER \$2, tt&R\*45842710

### Xi Nuo:

So I will tell you guys about the situation of the trial this morning. There were three witnesses being examined in the morning and the first one who testified was Wang Yamping. She wore plain clothes today and looked like she was in pretty good spirits. She was asked by the counsel whom she was representing and whom she worked for. She said she started working for the Guo family in 2009, and she worked for around 100 people in the family. Also, she said her main duty is to conduct research, prepare materials and documeñts for this family. She did not have the final say on other matters. What she meant was that she has nothing to do with these matters. The counsel then asked her if she knew about the purchase of this building by XXX, the off-shore compañy. She replied she didn't know. Yet, the counsel held a pile of papers and said, "You signed all these papers, but you knew nothing about these?" She then stammered and said she was super nervous, she had already forgotten these matters and please pardon her. So, it was obvious that she had lied on these matters.

## 3. Tweet: (2017/9/5)

htto


-F'F8:46 - 201749M 5 El

### Xi Nuo:

Wang Yanping showed up today and her voice is similar to that of hers in past recordings. It should be confirmed that it is the real Wang Yanping. Wang Yanping denied today that the recording of her haviñg sex with Guo Wengui published on Twitter was true. She even totally denied the reecided conversation between her and Ma Rui was true. She did not ec-¬^ª at all on the alleged rape Guo Wengui involved. She emphasized that she had been a CCP member for 18 years. She had expressed support for Guo's disclosing effort. The date of the interview is üñclear, Der Spiegel did not explain why it was not held in Guo's residence.

## EXHIBIT C

33 of 50

AFFIDAVIT

STATE OF NEW YORK ) COUNTY OF QUEENS ) ss

STATE OF NEW YORK ) ) ss: COUNTY OF QUEENS )

I, Shenyi Glass, am ^a linguist hired by TransPerfect, ^a translation services that operates under both ISO 9001:2008 and EN 15038:2006 certification. ^I have been speaking Mandarin dialect of Chinese for ⁵⁰

years. ^I am ^a recipient of Certifications for New York State Court Interpreter and National Healthcare

The following document is, to the best of my knowledge and belief ^a true and accurate translation from Chinese into English:

Interpreter. I have studied Mandarin translation for 5 years.

The Attached Social Media Posts TransPerfect Translations, Inc., ^a translation organization with over 90 offices on six continents, is ^a

translating into the above language pair, its work being accepted by business organizations, governmental

authorities and courts throughout the United States and internationally.

henyi Glass,

Mandarin Interpreter & Translator

TransPerfect Translations, Inc. affirms that the provided translation was produced in according to our ISO 9001:2015 and ISO 17100:2015 certified quality management system, and also that the agents responsible

leader in professional translations. TransPerfect Translations, Inc. has over twenty years experience

for said translation(s) are qualified to translate and review documents for the above language pair, and are not ^a relation to any of the parties named in the source document(s).

Sworn to before me this Wednesday, August 07, 2019

Signature, Notary Public

Stamp, Notary Public

Stamp, Notary Public

NOTARY PUBLIC-STATE OF NEW YORK No. 01 SH6352366 Qualified in Omos County My Commission Exµiies 12-2 1-26z6

**西诺 @sinofreedom · Jul 20**

王燕平和韩春光只有举报郭文贵才能自保。

**朱万利 @wanli198964 · Jul 20**

唐汉发推：据SV719反诉状，2018/1/6 当着Wallop夫人的面，王雁平笑着签署了本合同。Wallop夫人不认识汉字，王雁平也没有透露，她签的中文并不是她的名字，而是“韩春光”。这份合同落款是韩春光，这次签名与韩在其他证件上签名不一致，但是仔细观察还是能分辨出来。王雁平签字造假，谁给她的胆量？

8701 W. Sahara

Las Vegas, N Google 文档打开

Branch telephone: +1-702-228-2591

Subsequent payments will be made to the same account, unless mutually agreed otherwise in writing. It is understood that the Client may direct other entities to pay the Contractor, and that such payments will be deemed satisfactory compensation by the Contractor. All Client payments must be received by the Contractor by wire transfer within 5 business days of invoice.

Both parties anticipate that this contract could expand to many more subjects of research. The Client has expressly stated that there could be as many as 4000 such 'fish in the tank'. Obviously, negotiations for the far larger range will be agreed upon in writing at a later date.

**Duration.** This contract shall be in force for three (3) years from the date of signing. Either party may terminate the contract with 30 days' written notice.

| <i>French C. Wallop Signature</i> | <i>Chinese Signature</i> | |-----------------------------------|--------------------------| | French C. Wallop, CEO | | | Strategic-Vision US, LLC | | | Date: <i>Jan 6, 2018</i> | Date: <i>Jan 6, 2018</i> |

Duration. This contract shall be in force lor three 13) years tom the date of signing. Either party rnay terminate the cortract wth written notice.

http

signature. Who gave her this gut?

**Only when Wang Yanping and Han Chunguang report on Guo Wengui can they save themselves.**

French C. War p. CEO stree•ørxsen us. u.c

Q ¹² ² O ¹²

Tang Han tweeted: According to SV719 counterclaim, Wang Yanping signed the contract in this

case with ^a smile on her face on 01/06/2018 right in front of Mrs. Wallop. Mrs. Wallop doesn't read Chinese characters. Wang Yâñpiñg didn't mention that the Chinese name she signed isn't

Chungua.ng", of course this sig-±re is different from what Han has signed on other documents.

One can tell the difference if he observes it carefully in details. Wang Yañping fabricated the

her name, but Chinese character "Han Cheg-f rg". The signature on this contract is "Han

Yanping"

that she was raped by Guo

in a


Fyoutube.com

. .

1-1 ⁷ Q ⁸ 1


**New evidences that support Guo Wengui as a suspect of rape are:**

Show this thread

http

organization)

Wengui

1. The red wanted fugitive warrant issued by the Interpol (Proof of a written reply from the organization)

² Wine AMIMWWWWE En

- ⁵ WAR9@-em M -

New evidences that suppait Guo Wengui as a suspect of rape are:

2. The video clip of Guo Wengui's female employee cl ^g

3. The advertisement about Guo Wengui sciling his personal spcrms

1. The red wanted fugitive warrant issued by the Interpol (Proof of ^a written reply from the

Q ⁴⁰ ¹² ¹⁹ ⁷⁷

- 4. The audio clip of Guo Wengui raping and accaniting Wang Yanping - 5. The video clip of Guo Wengui sexually assaulting ^a man - 6. The video clip of Guo Wengui taking drugs with two women - 7. The news report about Guo Wengui sexually assaulting his daughter-in-law


His @sinofreedom Jul ¹³ v 4,51n\$ #EttTI\$fi|E

$\lor$ youtu.be/dGppXFIktxc?II... PublIshed b PublIshed an Sep 9 2017


. youtube.com


Show this thread

http

4. Guo Wengui sexually ases±cd and beat Wang Yanping

Published by: Chinese Channel

Pangu Boss Guo Wengui having sex with fcmaic secretary Wang Yanping in office (Season 8)

NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/08/2019

西诺 @sinofreedom · Jul 13

指控郭文贵为强奸犯的主要证据有三个:

| 1, | 美联社等16家西方媒体对郭文贵强奸女秘书的报道 | |----|----------------------------| | 2, | 马蕊在纽约法院状告郭文贵强奸的起诉书 | | 3, | 长达1小时40分钟的郭文贵和王燕萍审问马蕊的音频资料 |

加上新增加的7个证据, 总共10个证据。

你觉得还不够吗?

胖子 @d55IXPrNhhh1LWg · Jul 13

Replying to @sinofreedom

没说您杜撰, 郭骗什么尿性有点智商的都能看出来。就凭上面那几个事实而非的证据想拿下郭骗希望不大。郭骗已经臭大街了, 他还在乎再多一点脏水?

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1. ¹⁶ westem media compañics ir.ckding Associated Press reporting about Guo Wengui

audio clip of Guo Wengui and Wang Yanping interrogating

2. The legal complaint filed by Ma Rui in the New York Court, accusing Guo Wengui

Along with the ⁷ pieces of newly added evidace, there are ^a total of ¹⁰ pieces of evidence.

http There are 3 main pieces of evidence that support the charge against Guo Wengui as a rapist:

- -"-

raping ^a female secretary

raping her 3. The one-hour-fortf

Do you still think it isn't enough?

Ma Rui

NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/08/2019


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R9±\$2We4445. REMEREMERRHERM4EE. RT M@WHAfNEWK¥. Q ⁵ ¹² ¹ Q ¹¹


^I seldom heard about billionaires raping women when ^I was living in mainland China. The rich people usually used money to win the hearts of women, as raping not only is dangerous, it also

- - makes one person lose his social status. Once it is discovered, the rich man will lose face. The - business world also looks down on those low class guys who rely on raping women to expand

http

## audio recording. That is the voice of Guo Wengui and Wang Ping. It is hard to fabricate.

联社的报道佐证了部分事实。… , 请问该合同的签字人是不是你？你在:

the number of women they own. But what convinces me that Guo Wengui committed rape is that

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familiar with their voices.

http

- ^I believe my argu:nent is enough to coñviñcc the judge and the jury because my personal - knowledge is established based on the following:

2. I have the assessment reports from the Australian and Canadian voiceprint identification

1. ^I have had ^a lot of face-to-face contacts with Wang Yanping and Guo Wengui. ^I am


Etfililrd WMWitWjMMìIEE ? 5:21 AM - 11 Jul 2019 B Retweets 48 Likes

^I have listened to the recording of Guo Wengui and Wangyanpiñg's interrogation on Ma Rui ⁵

raped, for example, the underwear cent=-h=tad by bodily fluid, the blood-stained bed sheet, the

locations of the offenses and whether or not the boat staff and security guards were present etc. If

times. There are ⁹ occasions where Ma Rui was coerced to hand over the evidences of being

name of the pharmacy for getting birth-control pills, the number of times of being raped, the

the judge asks me next time why ^I think Guo is ^a rapist, ^I will reply, "If Guo Wengui didn't commit such an outrageous rape, why would he need to use every means to destroy these

Q ¹³ 1.3 ⁸ Q ⁴⁸

evidences?"

Follow

real."


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If the judge asks me, "How can you confirm that the audio clip about Wang Yanping and Guo

the analysis reports from Australian and Canadian voiceprint identification companies. The

believe that the audio clip about Wang Yanping and Guo Wengui interrogating Ma Rui is

report published by Associated Press has also corroborated with part of the facts. Therefore, ^I

My reply will be, "I have had face-to-face contacts with Guo Wengui on three occasions, while ^I have once with Wang Yanping. ^I am very familiar with their voices and intonations. Also, ^I have

¾†) ·

9 ² t-1 ¹ Q ¹¹

http

5:59 AM - 11 Jul 2019 1 Retweet 11 Likes


http

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In the case of Liar Guo suing Xia Yeliang, Guo origiñally had several witñêsses, but he withdrew

right path, there are more helps available to him; otherwise, none awaits him ahead. A thug who

all the witnesses at the very last minute. Evcataally it ended up with him being alone as the plaintiff and the only witness. He didn't even trust Wang Yanping who followed him for so many years, worrying that there might be unexpected things coming up. When ^a person is in

has no shame and trustworthiness will eventually head to the path of demise alone.


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Q ¹³ ¤ ²⁵ Q ⁸²

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Since the exposure of the audio clip about Guo Wengui and his secretary Wang Yanping interrogating Ma Rui together, Ms. Wang accepted the interview from Der Spiegel, leaving

recorded proof of her voice. After verification from the Australian J.-l; ;-1 authorities, the audio clip of Wang Yanping having an interview with Der Spiegel is the same as the audio clip of her


西诺 @sinofreedom · May 23

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show that you and Han Lianchan gave Strategic Vision a list of 96-people to be investigated. Are

you the one who signed that contract? What was your position in Eastem Profit? What is the purpose of you investigating these ⁹⁶ people? Where did the \$1,000,000 investigation fee come

Next time when (I) see Wang Yanping, (I) must ask her the following questions: Court papers

from? In what way was the money transferred to the States? How is this amount of money

There was an õecasioñ where Guo Wengui assaulted Wang Yanping after he got drunk. Not only

se B4HBUIJthatiB •

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recording of this audio clip

related to the Guo Wengui's money laundering case in Hong Kong? 515 @sinofreedom May ¹² W- WAnMWm8415%Em. MTRERI Eneman M+1 n

and be reunited with your husband and children, old Guo is unreliable."

http

http

Hi @sinofreedom RM15 W \$EEWARRWE@85•WMERA\$@RW-T4 \$

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twItter.com/TangHan3296711...

did he rape Wang, he also stepped on her belly violently. There was ^a


西诺 @sinofreedom · May 12

Hi§ @sinofreedom May ¹² RMIM W SE@WARRWEMBE-WWERAM RW-Tà \$2

| <div>[Text Thumbnail]</div> | <p><b>唐汉</b> @TangHan32967114</p> <p>母亲节特别专辑</p> <p>"当我离开中国时, 我的儿子是一岁五个月, 现在他差不多六岁, 该上学了."...</p> | |-----------------------------|---------------------------------------------------------------------------------------------------| |-----------------------------|---------------------------------------------------------------------------------------------------|

Q ²⁷ t-1 ⁹ O ³⁴


http ^I told Wang Yañpiñg that you have no future if you follow Guo Wengui. Guo never has any loyalty to his friends. He uses peopic when they have value to him and he throws them away like ^a piece of cleaég shred if they have lost their value to him. ^I hope that she can report to the NYPD accusing Guo Wengui raping and assaulting her. This action will turn her situation from

### losing to winning

Hi\$ @sinofreedom . May ⁵ v WNN1MWh?WEA 7, RGP AXE\$ ( NEE¥, RW:Eg

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## MR95, M85E9128.ET5, WÛReREERMS, WRM iÄMEil!lREM

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Yañpiñg before the PAX trial. ^I

\$2 @TangHan32967114 · May ⁵

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About the case of Guo Wengui suing the three people inch ding Ye Ling, ^I have asked Wang

said, "According to Guo Baosheng, this contract was drafted by

Yan."

Wang Yanping replied

you Wang Yanping, and har.ded over to Guo Baosheng and Zhao

Q ¹ t\_-1 O ¹² 1

Boss!"

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Hi\$ @sinofreedom · Apr ²⁸ v

4. R1-\*i&BMtâ2. DJMe±, iTRH&@E. EER&BET.

If Wang Yanping wants to save her own ass, the only way is to file ^a report in the police station, accusing someone for sexual assa--it The evidcñcc is very easy and simple, there are ^a lot of

spy for CCP,

that she didn't know and everything had been arranged by Guo Wengui. It looks like Guo Wengui was using ^a fake contract to test the loyalty of his followers. If the truth was found out,

evidence of sexual assault against Xi Nuo, and Guo Wengui has offered several millian dollars for the investigation. Hi§ @sinofreedom Apr ³⁰ v

he would sue the followers in court. It has been understood that the contract was designed to get

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money to hire female Yanping replied, "Smart

secretaries?"

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http 60?s=20

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| | <div><b>西诺</b> @sinofreedom · Apr 28</div> <p>我在与王燕萍交谈中谈到一个逻辑问题: A非C, B非C, 请问A等于B? 燕萍一脸茫然。我继续解释, 老共反郭, 西诺反郭, 请问老共等于西诺吗? 燕萍不吱声。我再解释, 我讨厌吃花椰菜, 布什总统也讨厌吃花椰菜, 西诺等于布什。燕萍笑了。</p> <div><span>9</span><span>1</span><span>27</span></div> | |--|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| |--|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|

**Show this thread**

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**FILED: NEW YORK COUNTY CLERK 08/08/2019 06:22 PM** INDEX NO. 157786/2019

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^I raised ^a logic question when ^I was having ^a conversation with Wang Yañ3pus, "A is not C, B is not C, then is A the same as B?" Yanping looked confused. ^I continued explaining, "Old CCP is against Guo, Xi Nuo is against Guo, then is Old CCP the same as Xi silent. ^I continued expla ning, "I hate eating cauliflowers, President Bush also hated eating cauliflowers, Xi Nuo is the same as President Bush." Yanping laughed.

Nuo?"

said, "Yanping, stop giving ycarself ^a hard

Yañpiñg stayed

unreliable."

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and, but I could tell she had her concerns and dilemma with no one to \$RHe8515 95 NSW:5 TEMENT E tWEfe


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To my surprise, ^I bumped into Wang Yanping today. She took the initiative to say hi to me. We were old seq2siñtsñces. ^I chatted with her for around ¹⁰ minutes. We talked about her work, her

When ^I said goodbye to Wang Yañpiñg yesterday, ^I

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time, go back home and be rc=ªra with your husband and children, old Guo is Yairpiñg didn't respond, but ^I could tell she had her concerns and dilemma with no one to

Hi§ @sinofreedom -

confide with. She is also a unfortunate kid. Lost her sense at one point!

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Apr 26

family and the ongoing lawsuits. We also talked about the people whom we are both fssi'isr with. Ms. Wang had sadness all over her face. She didn't comb her hair properly, and her face


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西诺 @sinofreedom · Feb 21

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http Based on the audio evidence that Wang Yañpiñg left, we conducted two separate and

indepcñdent voiceprint analyses in Australia and Canada at the same time. The analysis results

show that, the audio file of Wang Yañpiñg having an interview with Der Spiegel is highly

Show this thread

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money to you for your spy operation?

5% @sinofreedom . Feb ²¹ ^v

emihr to the voice recording of Wang Yaspiñg interrogatiñg Ma Rui.

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You directed Wang Yañpiñg to sign the contract with T&M compañy in Jan ²⁰¹⁸ and continue

to follow Ling Wa=¹·--=g. Was the cost for this contract from your loan as well? Who will lend

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西诺 @sinofreedom · Jan 14

RPG

IFf!

against Xia Yeliang and Li Hongkuan has alicady applied for withdrawal. What is surprising is that in Guo Wengui's confirmation letter that Daniel submitted to the court is setesily signed in Yanping's handwriting. This is very rare in ^a US lawsuit. The proper way of doing this sheüld be having ^a notary's stamp and signature. Does Liar Guo even want to save ² dollars in notary fee? This liar is really stupid!

It has been karned that the counsel Daniel Watt who is retained by Guo Wengui for ^a lawsuit

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recording released by RPG (a twitter account) isn't fake!

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^I remember ^I made ^a bet with Chen Xiaoping at that time, saying if Wang Yanping appeared on camera for an interview again, ^I would give him USD 200. In the end, ^I lost the bet. Not only did Wang Yañpiñg appear on camera, she also admitted she had been ^a CCP member for ¹⁸ years. ^I

then offered to give Chen Xiaoping the USD ²⁰⁰ that ^I lost in the bet when ^I encountered him later on. Chen Xiaoping just stared at me and then left. However, ^I had no bad intents (I) spent

USD 200 in exchange for an anthentic voice. ^I then sent the voice to Canada for an analysis. The

days."

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4, WM. Q ¹² LT ¹¹ Q ⁶⁵ 1 http 617344?s=20 Guo Wengui found that the front part of his shoe was worn yesterday. He asked Wang Yanping,

"This pair of leather shoes cost me USD 50,000, ^I have worn them for just ^a few days and they were torn! What's happened?" Yanping replied, "Boss Guo, you tiptoed too much these Guo said, "I have been tip-toeing for quite some time, my shoes weren't torn back then. Why would they be torn now?" Yanping said, "Boss Guo, you insisted on putting three layers of paint on ^a good pair of shoes, isn't that how the cow leather get torn?" Guo then said, "Whatever you say, it makes sense." Hi\$ @sinofreedom . Nov 2, ²⁰¹⁸ v

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Huang Hebian issued ^a public notice that there would be an announcement at PST ⁸ o'clock

regarding the last and trusted female subordinate of Guo betrayed him and left him without ^a

Guo-- Qu Guojiao, Yu Yong, Yang Xinxin, Ma Rui and Wang Yanping. Are there any of them

Yanping left, Guo's world will collapse in half. Take ^a look at the people who followed Liar

notice. Wondering if this lady is Wang Yanping. She is the steward that Guo trusted the most. If